Application of The Test
Applying the test above, the Grynberg court concluded that the prepayments satisfied the first prong. The prepayments were not mere deposits but irretrievable payments. However, the court found no valid business reason for making the payments in December rather than the following February or March when the payments were actually due. Because taxpayers failed the second prong of the test, the court did not apply the third requirement to the facts of the case. Because the prepayments were not necessary and ordinary business expenses for the year in which they were paid, the prepayments were not deductible.
Read more about this topic: Grynberg V. Commissioner
Famous quotes containing the words application of the, application of, application and/or test:
“Courage is resistance to fear, mastery of fear—not absence of fear. Except a creature be part coward it is not a compliment to say it is brave; it is merely a loose application of the word. Consider the flea!—incomparably the bravest of all the creatures of God, if ignorance of fear were courage.”
—Mark Twain [Samuel Langhorne Clemens] (1835–1910)
“The human mind is capable of excitement without the application of gross and violent stimulants; and he must have a very faint perception of its beauty and dignity who does not know this.”
—William Wordsworth (1770–1850)
“By an application of the theory of relativity to the taste of readers, to-day in Germany I am called a German man of science, and in England I am represented as a Swiss Jew. If I come to be regarded as a bête noire the descriptions will be reversed, and I shall become a Swiss Jew for the Germans and a German man of science for the English!”
—Albert Einstein (1879–1955)
“Just as we need to encourage women to test life’s many options, we need to acknowledge real limits of energy and resources. It would be pointless and cruel to prescribe role combination for every woman at each moment of her life. Life has its seasons. There are moments when a woman ought to invest emotionally in many different roles, and other moments when she may need to conserve her psychological energies.”
—Faye J. Crosby (20th century)